New GHG requirements for Voluntary Sustainability Schemes

From now, biofuel obligations in Germany will be based on a greenhouse gas (GHG) saving rather than a volume basis. EU-approved Voluntary Sustainability Schemes, such as the Roundtable on Sustainable Biomaterials (RSB), will play a key role in the new system. The German government presented important details about the new requirements in December.

A biofuel blender in Germany can meet their obligation with a smaller volume of a higher GHG saving biofuel in 2015. More producers are carrying out an actual GHG saving calculation, rather than using default values, to demonstrate the superior GHG savings of their product. The actual GHG savings achieved, the calculation method and verification are all therefore crucial operational details, which need to be worked out to enable the system to function correctly.

Waste materials have a GHG intensity of zero at the point of arising; they are therefore still attractive feedstock for biofuels, even though double counting has been abolished in Germany. So it is crucially important that the definition and verification of a waste material is robust and transparent.

Certain safeguards will be expected from Voluntary Sustainability Schemes to ensure that GHG savings claimed are verified and credible. The following points were presented during the December meeting:

• An indicative list of waste materials will be provided by the German government to assist auditors in making a decision about whether a biofuel is derived from a waste material.

• Operators reporting GHG intensities of 10% or more below the typical value for the same pathway will be notified to the relevant Voluntary Scheme.

• Details of the Voluntary Scheme (but not the operator) approving these lower GHG intensities will be reported to the European Commission.

• Those Voluntary Schemes that certify waste derived biofuels and that do not yet require verification of waste material back to the source, are strongly encouraged to change their Scheme to require this upstream verification as soon as possible.

• Biofuels based on animal fats or fish oils will not be accepted for the GHG quotas in Germany.

• An operator cannot perform GHG calculations on behalf of another operator upstream in the supply chain. So the GHG intensity of the crop production, must be carried out at the farm level and verified as part of the farm or first gathering point audit.

RSB has upstream verification of waste materials and this will be made a mandatory part of the RSB EU Renewable Energy Directive Standard and required for all EU Member States. RSB operators can accept biofuels certified by other EU approved Voluntary Schemes, providing the Voluntary Scheme requires upstream verification of waste material. This allows RSB operators to trade in Germany and use their system, NABISY.

RSB allows the use of the BioGrace and ENZO2 calculators that measure greenhouse gas calculations which have already been approved by the European Commission and the German government.